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ESTATE OF GERSON v. C.I.R.

No. 06-2582.

507 F.3d 435 (2007)

ESTATE of Eleanor R. GERSON, Deceased, Allan D. Kleinman, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: November 9, 2007.

Attorney(s) appearing for the Case

ARGUED: Mark A. Phillips, Benesch, Friedlander, Coplan & Aronoff, Cleveland, Ohio, for Appellant. Michelle B. Smalling, U.S. Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Mark A. Phillips, Jeffry L. Weiler, Benesch, Friedlander, Coplan & Aronoff, Cleveland, Ohio, Mark D. Tucker, Benesch, Friedlander, Coplan & Aronoff, Columbus, Ohio, for Appellant. Michelle B. Smalling, Richard Farber, Department of Justice, Washington, D.C., for Appellee. Matthew Yackshaw, Day, Ketterer, Raley, Wright & Rybolt, Canton, Ohio, for Amicus Curiae.

Before: COLE and COOK, Circuit Judges; and FROST, District Judge.

OPINION

COOK, Circuit Judge.

The Estate of Eleanor R. Gerson appeals the United States Tax Court's decision to assess a tax of $1,144,465 on the proceeds of an irrevocable trust under the generation-skipping transfer ("GST") tax. The Estate asserts that a grandfather clause protects these assets from taxation, despite a treasury regulation that would lead to a contrary result. Because the Commissioner's regulation reasonably construes an ambiguous statutory...

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